Report of the Air Pollution Prevention Forum

1 Draft Copy for Review Only

1 2 3 4

5 WRAP Policy

9 Renewable Energy and Energy Efficiency 10 As Pollution Prevention Strategies 11 For Regional Haze 12 13 14 15 16 17 Prepared by the 18 Air Pollution Prevention Forum 19 For the Western Regional Air Partnership 20 21 22

24 25 26 February 2003

2 1 1 Draft Copy for Review Only

1 2 Executive Summary 3 4 5 The Regional Haze Rule (Rule) requires each state to prepare a State Implementation 6Plan (SIP) and includes a separate section (Section 51.309) which allows the nine states that 7participated in the Grand Canyon Visibility Transport Commission (GCVTC) to base their SIPS 8on the regional recommendations of the GCVTC. Tribes are not subject to the same 9requirements of the Rule as states, but tribes wishing to assume the regional haze requirements 10outlined in the Rule may, according to the Tribal Authority Rule (TAR), seek approval under 40 11CFR 49 to be “treated as States.” Accordingly, throughout 12 13 The Western Regional Air Partnership (WRAP) was established by western states and 14tribes to coordinate and oversee implementation of the GCVTC recommendations and provide 15policy and technical tools to assist states and tribes in filing implementation plans. The GCVTC 16concluded that renewable energy and energy efficiency measures could result in “emissions 17reductions, improvements in visibility and provide secondary environmental and economic 18benefits to the region. Accordingly, states choosing to file a SIP under Section 309 are required 19to include descriptions of programs and policies each state will rely on to “preserve and expand 20energy conservation efforts” and contribute to meeting the regional goal for renewable energy 21established by the GCVTC. 22 23 The WRAP created the Air Pollution Prevention Forum to develop a set of policies and 24programs states and tribes could adopt to meet the GCVTC 10/20 renewable energy goal1 and 25increase the use of energy efficiency in the nine state Grand Canyon Visibility Transport region. 26 27 The AP2 Forum and its Tribal Issues Working Committee developed energy efficiency 28and renewable energy policy recommendations for states and tribes over a three-year period. In 29addition the AP2 Forum commissioned ICF Consulting to conduct a regional analysis of the 30emissions and economic impacts of implementing the AP2 Forum’s policy recommendations. 31The results of the regional modeling analysis, which apply to both states and tribes, demonstrated 32energy efficiency and renewable energy could result in emissions reductions, improvements in 33visibility, energy costs savings and provide secondary environmental and economic benefits to 34the region. 35 36 It is the policy position of the WRAP that joint implementation of the AP2 Forum’s 37renewable energy and energy efficiency policy and program recommendations will reduce 38emissions and electricity production costs in the region, will result in a larger emissions benefit 39than either measure by itself, and will meet the requirements of the Regional Haze Rule. 40Furthermore, the most significant progress towards meeting the GCVTC renewable energy goals 41and increasing the use of energy efficiency in the region is best accomplished through the 42adoption of state and tribal policies that provide financial incentives. States and tribes in the 43WRAP region should also adopt complementary polices that will improve the efficiency of the

2 1 The GCVTC recommended that “[t]he goal of the states in the Transport Region should be to achieve 3annual additions in order that renewables will comprise 10% of the regional power needs by 2005 and 20% by 42015” region” .

1market place such as green pricing programs, consumer education and information disclosure 2rules, regulatory policies and utility rate reforms. Finally, the WRAP acknowledges the 3important role of federal policies and regional institutions have in improving efficiency of the 4market place and in increasing the development of renewable energy and deployment energy 5efficiency in the WRAP region. 6 7 The WRAP Policy on renewable energy and energy efficiency embodies the AP2 8Forum’s recommendations analysis and further reaffirms the findings of the GCVTC. The 9policy adopted is purposely broad. The WRAP recognizes state and tribal diversity in the region 10and has endorsed this policy statement as guidance for states and tribes to use as they develop 11their individual implementation plans. Accordingly, while the WRAP has not specifically 12adopted every one of the 40-plus policy and programs recommendations of the AP2 Forum in 13this policy statement, it has directed the Initiative Oversight Committee to forward 14recommendations and reports of the Air Pollution Prevention Forum to states and tribes for their 15consideration and use in the development of State/Tribal Implementation Plans for regional 16haze. 17

1 Table of Content 2 3 4Executive Summary 5 6 7WRAP Policy Statement on Renewable Energy and Energy Efficiency 8 9Background 10 11Grand Canyon Visibility Transport Commission 12 13Regional Haze Rule: Renewable Energy and Energy Efficiency 14 15Western Regional Air Partnership 16 17Air Pollution Prevention Forum 18 19Findings of the Air Pollution Prevention Forum 20 21Renewable Energy 22 23Energy Efficiency 24 25Regional Emissions and Economic Impact Analysis 26 Regional Generation Capacity 27 Emissions Reductions 28 Energy Costs Impacts 29 Secondary Regional Economic Impacts 30 31Policy Recommendations of the Air Pollution Prevention Forum 32 33Renewable Energy Policies for States and Tribes 34 Specific Tribal Recommendations 35 36Energy Efficiency Policies for States and Tribes 37 Specific Tribal Recommendations 38 39 40Appendices 41 42Appendix I – Pollution Prevention 51.309(d)(8) 43 44Appendix II – Membership of the Air Pollution Prevention Forum

1 2Appendix III – Meetings of the AP2 Forum 3 4Appendix IV – Reports of the AP2 Forum 5 6Appendix V – List of Renewable Energy Policies and Programs 7 8Appendix VI – List of Energy Efficiency “Best Practices” 9 10Appendix VII – Energy Efficiency “Best Practices: Costs of Saved Energy

1 WRAP Policy on Renewable Energy and Energy Efficiency 2 3 4 The WRAP policy on renewable energy and energy efficiency is intended to reaffirm the 5Grand Canyon Visibility Transport Commission findings that renewable energy and energy 6efficiency measures result in “emissions reductions, improvements in visibility and provide 7secondary environmental and economic benefits to the region”. The policy also embodies the 8analytical modeling results and policy analysis undertaken by the Air Pollution Prevention 9Forum to assist both states and tribes with the development of their regional haze implementation 10plans (SIPS/TIPS). 11 12 The policy is purposely broad. The WRAP recognizes state and tribal diversity in the 13region and has endorsed this policy statement as guidance for states and tribes to use as they 14develop their individual implementation plans. Accordingly, while the WRAP has not 15specifically adopted every one of the 40-plus policy and programs recommendations of the AP2 16Forum in this policy statement, it has directed the Initiative Oversight Committee to forward 17recommendations and reports of the Air Pollution Prevention Forum to states and tribes for their 18consideration and use in the development of State/Tribal Implementation Plans for regional haze 19that make sense for their unique circumstances. 20 21 22WRAP Policy 23 24 Following on the findings of the Grand Canyon Visibility Transport Commission 25(GCVTC), the WRAP finds that energy efficiency and renewable energy can be effective tools to 26reduce regional haze and, if adopted by states and tribes in the Transport Region, could result in 27emissions reductions, improvements in visibility, energy costs savings and provide secondary 28environmental and economic benefits to the region. The WRAP expects that these tools will be 29implemented in a manner that protects cultural resources. The WRAP believes that states and 30tribes2 can make progress towards meeting the GCVTC 10/20 renewable energy goal3 and 31increase the use of energy efficiency technologies in the Grand Canyon Visibility Transport 32region, and adopts the following policy statements: 33

22 Under the Regional Haze Rule (40 CFR 51.309(d)(12)) and the Tribal Authority Rule (40 CFR 49.1-49.11), tribes 3within the Grand Canyon Visibility Transport Region may, but are not required to, receive delegation of federal 4authority to adopt Tribal Implementation Plans (TIPs) under Section 308 or 309 of the Regional Haze Rule. Tribal 5selection of Section 308 or 309 is independent of the strategy adopted by the state(s) in which the tribe is located. In 6addition, tribes may apply for approval of “reasonably severable” elements of Clean Air Act programs. Further, 7deadlines for plan submittal that apply to states do not apply to tribes. Where a tribe opts not to develop a TIP, EPA 8may work with the tribe to adopat a Federal Implementation Plan (FIP) if necessary and appropriate to protect air 9quality. 103 The GCVTC goal is: 10 percent of generation from renewable resources in 2005 and 20 percent in 2015. With 11respect to the requirements of Section 309(d)(8), achieving the 10/20 goal is not mandatory or “enforceable.”. This 12section of the rule does establish an “enforceable” requirement for States “to assess progress toward a goal 13established by the GCVTC with respect to renewable energy”. To the extent they are not able meet the goal, States 14are required to provide an explanation of why the goals cannot be met. See Federal Register, Vol. 64, No. 126, 15page 35754, July 1, 1999. Regional Haze Regulations Final Rule.

1 1. Joint implementation of the AP2 Forum’s renewable energy and energy efficiency policy 2 and program recommendations will reduce emissions and electricity production costs in 3 the region, will result in a larger emissions benefit than either measure by itself, and will 4 meet the requirements of the Regional Haze Rule. 5 6 2. State and federal economic incentives and policy changes are necessary if states and 7 tribes are to successfully make progress towards meeting the GCVTC 10/20 renewable 8 energy goal (10 percent of generation will come from renewable energy by 2005 and 20 9 percent by 2015) and increase energy efficiency in the Transport Region. 10 11 3. Electricity consumers in the Transport Region should be given the opportunity to choose 12 renewable electricity products and services through viable green marketing or green 13 pricing programs. 14 15 4. States and tribes should take policy actions to improve the efficiency of the market place, 16 such as providing 1) access to information about the price, sources of power and 17 environmental impacts of their power purchases, and 2) accurate price signals. 18 19 5. States and tribes should: encourage utility and/or State sponsored demand side 20 management programs; develop minimum energy efficiency standards for buildings; and 21 modify regulatory approaches to include in SIPS and TIPS credit for emissions 22 reductions of criteria pollutants from energy efficiency measures. 23 24 6. Actions should be taken to reform transmission access, pricing and interconnection 25 policies that create barriers to the movement of renewable energy generation from 26 generators to customers. 27 28 7. An emissions cap-and-trade program is an economically efficient method of achieving 29 emissions reductions and provides economic incentives to develop renewable energy 30 generation and energy efficiency measures. 31 32 8. Some policies are more effective if implemented on a regional scale. States, tribes and 33 regional energy organizations should act in concert to: establish a regional institution for 34 issuing and trading renewable energy certificates; institute a regional generation tracking 35 system; reform transmission management practices that discriminate against intermittent 36 renewable resources; and participate in energy efficiency market transformation 37 programs. 38 39 9. States and tribes should support Federal policies that would increase development of 40 renewable energy in the Transport Region including extension of the federal production 41 tax credit for wind, biomass and geothermal through 2015, or until these renewable 42 energy resources become cost-competitive in the region. 43 44 10. States and tribal governments and federal agencies should “lead-by-example” by 45 becoming early adopters of renewable energy and energy efficient products, services, and 46 practices in a manner that protects cultural resources.

1 Background 2 3 4Grand Canyon Visibility Transport Commission 5 6 In 1977 Congress established provisions to improve visibility in 156 national parks and 7wilderness areas across the United States as part of the Clean Air Act Amendments of 1977(Act). 8Congress further addressed visibility in western Class I areas in creating the Grand Canyon 9Visibility Transport Region (Transport Region) and directing EPA to establish the Grand Canyon 10Visibility Transport Commission (GCVTC) to address haze causing pollutants in a nine state 11region whose emissions affected the visibility of the Grand Canyon.4 The Commission was 12charged with making recommendations on how to protect and improve visibility in 16 national 13parks and wilderness areas on the Colorado Plateau. 14 15 In 1996, after 5 years of technical assessment and policy development, the Commission 16issued its report to EPA recommending a suite of 12 emissions control strategies that if adopted 17as a single package would improve visibility throughout the Colorado Plateau.5 18 19 The report concluded that although the GCVTC did not have the resources necessary to 20“model or completely quantify the effects” of renewable energy and energy efficiency on 21visibility, if implemented, these measures could result in “emissions reductions, improvements in 22visibility and provide secondary environmental and economic benefits to the region.” 6 23With regard to renewable energy7, the GCVTC recommended that “[t]he goal of the states in the 24Transport Region should be to achieve annual additions in order that renewables will comprise 2510% of the regional power needs by 2005 and 20% by 2015” (the 10/20 goals). The GCVTC 26also found there was an opportunity to realize visibility improvements from energy efficiency.8 24 The Commission was comprised of the governors of eight states (Arizona, California, Colorado, Nevada, New Mexico, Oregon, 3Utah, and Wyoming) as well as the President of the Navajo Nation, the Chairman of the Hopi Tribe, the Pueblo of Acoma 4Governor and ex-officio members from the Environmental Protection Agency, the Bureau of Land Management, the National 5Park Service, the U.S. Forest Service and the U.S. Fish and Wildlife Service. 65 Report of the Grand Canyon Visibility Transport Commission to the U.S. Environmental Protection Agency: 7Recommendations for Improving Western Vistas, June 10, 1996. 86 Ibid, pg.28 97 The Air Pollution Prevention Forum adopted the following definition of renewable energy. "Renewable energy" is 10defined as electricity generated by non-nuclear and non-fossil low or no air emission technologies using resources 11that are virtually inexhaustible, reduce haze, and are environmentally beneficial. The term includes electricity 12generated by wind energy technologies; solar photovoltaic and solar thermal technologies; geothermal technologies; 13technologies based on landfill gas and biomass sources, and new low-impact hydropower that meets the Low-Impact 14Hydropower Institute criteria. Biomass includes agricultural, food and wood wastes. The term does not include 15pumped storage or biomass from municipal solid waste, black liquor or treated wood. 168 “The Commission supports the continued development and implementation of national energy efficiency 17standards for motors, appliances and lighting and recommends the national adoption of the California energy 18efficiency standards. The Commission also supports the construction of energy efficient buildings, both 19residential and commercial, and proposes the reinstatement of incentives for building energy efficient 20structures.…The Commission also suggests the continuation of demand-side management programs, despite 21current funding restrictions. The Commission recommends that continuing attention be paid to maintaining 22the role of energy conservation within the changing electric power industry markets. Energy conservation 23programs should be preserved and expanded through such mechanisms as “system benefit charges” paid at 24the distribution level....” Report of the Grand Canyon Visibility Transport Commission to the United States 25Environmental Protection Agency, June 1996, pages 31-32.

1 2Regional Haze Rule and Renewable Energy And Energy Efficiency 3 4 In July 1999, the Environmental Protection Agency issued its final regional haze 5regulations.9 The final “Regional Haze Rule” requires each state to prepare a State 6Implementation Plan (SIP) for regional haze and includes a separate section (Section 51.309) 7which allows the nine Transport Region states (Arizona, California, Colorado, Idaho, Nevada, 8New Mexico, Oregon, Utah, and Wyoming) to implement a regional approach to reducing haze 9and base their SIPS on the regional recommendations of the GCVTC.10 As provided by the 10“tribal authority rule11,” (TAR) eligible tribes may implement Clean Air Act programs to protect 11air resources “within the exterior boundaries of the reservation or other areas within the tribe’s 12jurisdiction.” Tribes too, may choose to participate in the regional approach granted to the states 13in the Transport region and submit a Tribal Implementation Plan (TIP) containing elements 14described in section 51.309. 15 16 States choosing to pursue the 309 path are required to include a variety of information 17addressing energy efficiency programs, renewable energy production and consumption, and 18descriptions of programs and policies each state will rely on to contribute to meeting the 19GCVTC’s regional goal for renewable energy. The requirements of the regional haze rule 20regarding energy efficiency and renewable energy are found in 40 CFR 51.309(d)(8). This 21section addresses the GCVTC’s recommendations on pollution prevention, renewable energy, 22energy efficiency and conservation. With respect to renewable energy and energy efficiency 23Section 51.309(d)(8) requires each state SIP to provide: 24 25  A description of the programs relied on to achieve the State's contribution to the 26 Commission's goal that renewable energy will comprise 10 percent of the regional power 27 needs by 2005 and 20 percent by 2015 (10/20 goal). 28  A demonstration of the progress toward achievement of the renewable energy goals in the 29 years 2003, 2008, 2013, and 2018. 30  A summary of programs to preserve and expand energy conservation efforts, and 31  Projections of the short- and long-term emissions reductions, visibility improvements, cost 32 savings, and secondary benefits associated with the renewable energy goals, energy 33 efficiency and pollution prevention activities. 34 35 For tribes that choose to submit a TIP following the GCVTC regional approach, the 36content may contain elements similar or identical to that just described for a Section 309 SIP. 37However, there is considerable flexibility in how, when, and whether a tribe may develop a TIP. 38Under the TAR, tribes are not subject to deadlines for TIPS, nor to sanctions if TIPS are not 39adopted. To encourage tribes to develop air-quality management programs, however, the TAR 40authorizes a modular approach to tribal programs; that is, tribes can build their technical and 41management capacity at the same time they begin to address concerns specific to their priorities. 42This modular approach provides several opportunities:

29 Federal Register, Vol. 64, No. 126, pages 35714-35774 (July 1, 1999) 310 States other than those that participated in the GCVTC must utilize the rules and standards adopted by EPA under 4Section 308. 511 40 CFR Part 49

1 2  Tribes can pick and choose among Clean Air Act provisions to craft a program that 3 addresses the tribe’s specific air-quality concerns. 4  The EPA can approve these modular programs provided that they do not depend on 5 any other program element for enforceability. 6 7  To encourage tribes to develop air quality management programs, grants are available 8 from the EPA pursuant to Sections 103 and 105 of the Clean Air Act. 9 10 Thus, it may be possible for a tribe to obtain EPA approval to implement renewable 11energy or energy efficiency measures, or both, as part of a 309 TIP without implementing other 12parts of 309 which are not appropriate for the tribe. 13 14 15Western Regional Air Partnership 16 17 Western Regional Air Partnership (WRAP) was established in 1997 as the successor 18organization to the GCVTC. The WRAP and was created by western states and tribes to 19coordinate and oversee the implementation of the recommendations of the GCVTC and “identify 20regional or common air management issues, develop and implement strategies to address these 21issues, and formulate and advance western regional policy positions on air quaily.”12 Policies, 22strategies and technical tools are developed through an inclusive stakeholder-based process that 23includes state air agencies, EPA, tribes, federal and state land management agencies, local 24government, industry, utilities, environmental groups, academia and other interested parties. 25 26 27Air Pollution Prevention Forum 28 29 The Air Pollution Prevention (AP2) Forum was created September 1998 by the WRAP’s 30Initiatives Oversight Committee (IOC) and charged to: 31 32 “Recommend legislative actions, economic incentives and regulatory policies states can 33 adopt to meet the 10/20 renewable energy goal and increase the use energy efficiency 34 technologies in the Grand Canyon Visibility Transport region.” 35 36 37 As is the expectation of all WRAP forums, the objective of the AP2 Forum and its 25 38members has been to provide the states and tribes of the WRAP region with the policy and 39analytical framework needed to respond to the requirements of the Pollution Prevention section 40of the Regional Haze Rule.13 To accomplish this purpose the AP2 Forum’s work plan called for 41the Forum to: 42 43  Examine barriers restricting the penetration of renewable energy, energy efficient 44 technologies, and adoption of energy efficient practices in the Transport Region;

212 WRAP Charter,, Purpose, p. 1. 313 40 CFR 51.309(d)(8).

1  Identify and evaluate economic incentives, legislative actions, and regulatory policies that 2 will increase investments in renewable energy and energy efficiency, including actions 3 currently underway in the Transport Region; and 4  Recommend market-based incentives and public policies that will support increased 5 investment in renewable energy within the Transport Region and improve the efficiency 6 of the region’s energy production and end-use sectors. 7 8 The AP2 Forum’s recommendations have been developed over a three-year period 9through a stakeholder-based consensus process supported, in part, by nationally recognized 10renewable energy and energy efficiency experts, including the National Renewable Energy 11Laboratory. The Forum and workgroups held more than 11 meetings and workshops to examine 12barriers and identify policies that would lead to increased investment in renewable energy and 13energy efficiency in the Transport Region. The Forum also commissioned ICF Consulting 14Group to analyze the potential emissions reductions, energy costs, and secondary environmental 15and economic benefits to the Transport Region of meeting the GCVTC 10/20 goal and 16implementing a suite of cost-effective energy efficiency programs and policies the AP2 Forum 17identified as “best practices” for the region. 18 19 As a result of its investigation the AP2 Forum prepared seven reports that provide policy, 20analytical and technical support for the Forum’s policy recommendations to the WRAP, states 21and tribes. These documents are listed in Appendix IV.

1 Findings of the Air Pollution Prevention Forum 2 3 4Renewable Energy 5 6 A substantial increase in power generation from renewable energy is needed for the 7Transport Region to attain the GCVTC 10/20 goal. In 1999 the Transport Region supported 86,190 MW of renewable generation capacity, representing six percent of the regions electricity 9supply. Based on forecasts of demand for electricity in the region for the period 2001-2018, the 10AP2 Forum estimates that in order to meet the goal of 20 percent renewable energy generation in 112015 , over 20,000 MW of new renewable energy generation capacity will need to be brought 12on-line in in the Transport Region over the next 16 years. 13 14 The AP2 Forum finds that despite the enormous renewable energy potential of the West 15there are a number of barriers that are preventing the greater use of renewable energy in the 16region. The biggest barrier renewable energy currently faces is cost. With the exception of high 17quality wind resources, generation from renewables is, in most cases, more expensive than 18conventional electric technologies. Higher costs can be accounted for by market imperfections 19and other barriers renewables face. For example, existing tax structures penalize capital- 20intensive renewable energy technologies compared to competing conventional technologies. 21Current transmission pricing and access protocols penalize intermittent generation resources such 22as wind and solar. Benefits of renewable energy, such as reduced environmental impacts, are not 23monetized in the power market and there is a lack of information and consumer knowledge about 24electricity sources and their environmental impacts. Monopoly electricity providers are often not 25required to provide “choice” in sources of electricity supplied to end-use consumers. 26 27 The Forum finds that the most significant progress towards meeting the 10/20 renewable 28energy goals can best be accomplished though the adoption of state policies which provide 29financial incentives for the production and consumption of renewable energy. The Forum 30believes that renewable portfolio standards (RPS) and system benefits charges (SBC) are the 31most effective state policy options for encouraging the growth of renewables. Other financial 32incentives include state and federal tax incentives14, and State government agency renewable 33energy purchase requirements. Tribes may also find adoption of RPSs and SBCs useful policy 34tools in promoting renewable energy and may wish to consider these in the context of an overall 35tribal energy policy. Furthermore, since tribes generally don’t benefit from tax incentives, tribes 36may consider seeking alternative yet equitable incentives to encourage development of 37renewable energy on tribal lands (such as tribal block grants). 38 39 The Forum finds that electricity customers who want to purchase renewable generated 40electricity should be given the option of purchasing a percentage of their power from renewable 41energy through a viable green market or green pricing program. In order to improve the 42performance of these programs, states and tribes should also adopt complimentary policies that 43will improve the efficiency of the marketplace and lower transaction costs for “green” electricity 44products and services.

214Including production tax incentives, personal and corporate income tax credits, property tax incentives and sales 3tax exemptions from purchases of renewable energy equipment or electricity.

1 2 In addition, complimentary federal and regional policies are necessary to encourage 3progress towards meeting the GCVTC 10/20 goal. The Forum finds that there are a number of 4federal policies and programs that can help the Transport Region make progress in meeting the 5GCVTC 10/20 goal. There are also several necessary policies that, if implemented in 6conjunction with other public policies, are more effective on a regional scale. These include 7trading of renewable energy certificates and creation of a generation tracking system for the 8western interconnected system. 9 10 States are already making progress toward implementing the GCVTC’s recommendations 11and the requirements of Section 309(d)(8), including adoption of significant Renewable Portfolio 12Standards (e.g., 20 percent in California and 15 percent in Nevada), tax incentives (e.g., Arizona, 13Idaho, Nevada, New Mexico, Oregon, Utah), green power purchase programs, and 14implementation of utility least-cost resource acquisition strategies (e.g., wind generation 15construction in Colorado). 16 17 Tribal lands in the WRAP region have great potential for the development and delivery of 18electricity generated from renewable resources. Furthermore, many tribes are interested in 19generating, selling, and using such electricity. Consequently, tribal energy programs can be 20significant contributors to the 10/20 goal. Substantial barriers exist, however, to the full 21implementation of tribal opportunities for development of renewable energy resources. For 22example, many tribes do not have an energy authority or an energy policy, and are consequently 23not well positioned to take advantage of opportunities related to renewable energy. Also, and of 24particular importance to rural residents, is the fundamental need for basic electric service or for 25reliable electric service. Because development of renewable resources is a capital-intensive 26activity, access to capital can also be a significant barrier. Thus while the potential to develop 27renewable energy exists, tribes with the desire to do so will face significant challenges beyond 28those cited above for states. 29 30 The AP2 Forum has recognized that the special relationship of Indians Tribes and their 31lands within the federal framework has great bearing on strategies to enhance renewable energy 32development. That is, tribal-state-federal relations must be considered in their legal, economic, 33and cultural contexts when exploring the development and delivery of electric energy across 34political boundaries. Because these relationships are markedly varied, appropriate strategies will 35differ from tribe to tribe, and the concept of setting priorities among alternative strategies must 36be left to individual tribes. Tribes may select and pursue these strategies in the context of their 37overall goal of maintaining and strengthening their cultural, social, economic, and political 38integrity. The recommendations presented to tribes by the AP2 Forum represent a broad selection 39of opportunities from which the tribes in the WRAP region and their collaborators can choose 40according to their specific circumstances. 41

1Energy Efficiency 2 3 The Forum began its work on Energy Efficiency in June of 2000 with an initial 4examination of demographic and economic trends likely to affect future electricity consumption 5in the WRAP region. Existing state and tribal policies were reviewed along with federal/state 6programs relating to energy efficiency, and opportunities were identified to improve energy 7efficiency in the region’s economy. The Forum then identified market and institutional barriers 8that could restrict penetration of energy efficiency technologies and conservation practices and 9developed a list of state policies and “best practices” that, if adopted by states and tribes would 10enable the region to increase the level of efficiency in the production and end-use of electricity. 11Also developed was a set of recommendations specifically directed to tribal leaders that could 12foster implementation of energy efficiency on tribal lands. The impact these policies and energy 13efficiency programs and measures would have on regional emissions and energy costs were then 14evaluated. 15 16 The AP2 Forum found a wide range of cost-effective energy efficiency measures exist 17 that provide a substantial opportunity to improve the efficiency of electricity use in the region.15 18 However, there are also a number of barriers that prevent widespread penetration and use of 19 energy efficiency technologies and adoption of energy conservation practices.16 20 21 Adoption of energy efficiency measures in the economy is a dynamic process involving 22interactions between technology, consumer behavior, market conditions, and public policy. 23Given the persistence of market barriers, the Forum finds that there are a number of important 24public policies and programs that can help overcome these barriers and increase market 25penetration of energy efficiency technologies in the Transport Region’s economy. This can best 26be accomplished through financial incentives and mandatory energy efficiency standards. The 27Forum found there are other programs and policies that can help promote energy efficiency and 28conservation including consumer information and education, utility and environmental 29regulatory policies, and utility rate reforms. 30 31 Western tribes have the potential to implement and, in some cases, to lead innovative 32programs that improve energy efficiency. This Forum recognizes the great diversity of tribal 33lands in the region and the inherent need for tribal governments to selectively pursue energy- 34efficiency opportunities. For example, some tribes place a high priority on the need to provide 35basic reliable electric service to their residents and businesses; there are innovative opportunities

215 The AP2 Forum identified 43 programs and measures that represented “best” energy efficient practices in the 3region. No measure’s cost of “saved energy” exceeded $0.054/kWh and all measures taken together averaged 4$0.0186/kWh of energy saved. By comparison, “avoided costs” for electricity from new gas-fired generation 5averages between $0.036 and $0.046 kWh. These measures were not meant to represent all cost-effective options or 6all technically feasible energy efficiency options that would have environmental benefits. Rather they represented a 7set of achievable, cost-effective programs that would provide significant energy savings if a state chose to pursue a 8moderately ambitious level of energy efficiency. 9 16 Barriers include lack of consumer awareness and limited access to information about energy efficient products, 10 services and effectiveness of energy efficiency measures in reducing energy use and costs; emphasis on lowest first 11 cost in purchasing equipment or constructing buildings; limited product availability in the marketplace; energy 12 price distortions, e.g. “average cost” pricing of electricity prevents consumers from seeing the true costs of 13 electricity use; and competition for limited internal investment capital results in business decisions to invest in 14 energy efficiency being delayed or poorly executed.

1for energy conservation measures in the design and development of these services. Other tribes 2fully-served with reliable electricity may want to concentrate on improving the efficiency of 3electricity applications. Virtually every tribe may be interested in the economic benefits offered 4by energy-efficiency programs as well as the related social and cultural benefits. With potential 5cost savings on electricity expenditures (as well as other energy sources) on the order of 15% to 650%, energy-efficiency programs and policies could have a significant positive impact that 7extends beyond air quality and economics to tribal sovereignty, energy independence, and 8increased revenues to fund other tribal priorities. . The Forum recommendations offer a broad 9selection of options from which tribes in the WRAP region can choose according to their specific 10circumstances.

1Regional Emissions and Economic Impact Analysis 2 3 In its 1996 report, the Grand Canyon Visibility Transport Commission (GCVTC) 4recommended future modeling work be conducted to analyze the potential emissions reductions, 5visibility improvements, costs savings, and secondary benefits associated with the use of 6renewable energy and energy efficiency.17 The AP2 Forum commissioned ICF Consulting to 7conduct modeling analysis using policy scenarios and cost assumptions developed by the Forum. 8This analysis was conducted to help the AP2 forum understand the potential emissions 9reductions, costs and secondary regional economic impacts of the implementing the 10/20 goals 10and the energy efficiency recommendations. The AP2 forum developed two types of scenarios 11in order to examine the emissions, costs and secondary regional economic impacts of meeting 12the 10/20 goals and implementing the energy efficiency recommendations. 13 14 15

WRAP/MTF Economic Analysis Economic Impacts of Implementing a  Served as starting point for Regional SO2 Emissions Program in the Grand Canyon Visibility Transport Region Volume I analysis Prepared for: Western Regional Air Partnership WR Market Trading Forum Prepared by:  AP2 selected Annex Scenario as ICF Consulting AP/ Septem ber 2000 Business-As-Usual scenario

Phase I: MTF AP2 Forum Assumptions and Econ  Reviewed and revised assumptions Scenario Development for renewable energy technology omic  Developed energy efficiency cost and performance assumptions -  Developed scenarios for analysis of 10/20 goals and energy efficiency Anal (EE) ysis

Electric Markets

Phase II: IPM® Modeling Modeling of Electric  Modeled 10/20 and EE Scenarios developed under Phase I and Steam Sector Integrated Approach Electric/Steam Sector System Impacts

Environmental Fuel Emission Impacts Markets Markets Production Cost Impacts

Output Final Demand by Type Output by Industry REMI™ Modeling Phase III: Supply Market Shares Demand Population Local and export  Secondary regional economic Modeling of by Age, Employment market shares Gender, Race Demand by Industry impacts Secondary Labor Supply by Industry, by Occupation Employment Impacts Economic Impact Wage Rate Gross Regional Product Wage Rate, Prices and Profits by Industry Impacts Income Impacts 217 Report of the Grand Canyon Visibility Transport Commission to the U.S. Environmental Protection Agency: 3Recommendations for Improving Western Vistas, June 10, 1996, pg. 29. 4

1 2 The first was the Business-As-Usual (BAU) scenario that characterized how the future 3might unfold with the proposed regional backstop SO2 trading program but without any policy 4measures designed to accomplish the 10/20 goals and energy efficiency recommendations. The 5second set of scenarios reflected a future with the regional backstop SO2 trading program and 6policy drivers designed to meet the 10/20 goals or energy efficiency recommendations, or both. 7Assessments of emissions, costs and secondary regional economic impacts were estimated by 8analyzing the changes in the policy scenarios relative to the BAU scenario. 9 10 11Changes in Regional Generation 12 13 Implementation of the energy policy recommendations to achieve the 10/20 goals will 14lead to significant growth in renewable energy capacity, totaling 20 GW by 2018. The growth 15reflects the requirements of the 10/20 goals and the assumption that the policy climate of the 1610/20 goals may better align incentives to spur the improvements in renewable technology cost 17and performance through accelerated learning by doing and by easing some of the barriers to 18entry for renewable energy. Figure ____ below summarizes the growth in renewable energy 19capacity under the 10/20 goals. On the basis of economics wind power dominates most of the 20growth in new renewable capacity and the increased use of renewable energy displaces new gas- 21fired generation. 22 23 24 Figure ___: Renewable Energy Capacity Additions Under the 10/20 Goals 25 25 ) W G (

20 8 1 0 2

s n o i t i

d 10 d A

c 5 a p a C 0 26 Wind Geothermal Landfill Gas 27 28 29 Achieving the energy efficiency policy and “best practices” recommendations developed 30by the AP2 forum will lead to electricity demand reductions in the Transport Region of 8 percent 31by 2018 resulting in energy savings of 54,000 Gigawatt hours (GWh) and summer peak demand 32savings of over 16,000 MW of capacity. 33 34Emissions Reductions 35 36 The important results in capacity changes of the 10/20 goals and energy efficiency is that 37new renewable energy capacity and energy conservation compete against new conventional

1capacity while leaving the existing electricity generation stock relatively undisturbed. This has 2important implications for size of emissions reductions. 3 4 The modeling analysis of emissions reductions indicates that implementation of the 10/20 5goals and energy efficiency “best practices” could result in savings in NOx emissions of 6between 8,000 tons and 14,000 tons (or 1 percent to 2 percent relative to baseline conditions in 7the BAU scenario).18 The reduction potential is relatively modest because the displaced 8generation consists almost entirely of new cleaner burning gas-fired combined cycle units. 9Nonetheless, the modeling shows that the 10/20 goals and energy efficiency can provide a hedge 10against future emissions growth. In conjunction with other WRAP emission control strategies, 11the emission reductions from efficiency and renewable energy can help improve visibility in the 12region. 13 14 Implementation of the 10/20 goals and energy efficiency scenarios does not reduce SO2 15emissions per se because of the regional SO2 cap and trade program proposed under a separate 16part of Section 309 of the regional haze rule. Under a cap and trade program any SO2 emissions 17reductions from renewable energy and energy efficiency is fully offset by increases in SO2 18emissions from sources that are allowed to emit up to the emissions cap. However, the 10/20 19goals and energy efficiency could decrease the compliance cost of the SO2 trading program by as 20much as $ 7 million (or 10 percent of projected compliance cost19) in 2018 and could displace the 21need to install 1,200 MW to 1,700 MW of new scrubber capacity by 2018. 22 23 24 Figure___: Potential NOx Emissions Reductions Under the 10/20 Goals and Energy Efficiency 25 Recommendations 26 27 U

B 16 10/20 Goals 29 o t

) 30 e 14 EE X v i t 31 O a EE + 10/20 Goals N l 12

32 e f o R

s 10 33 n n o i 34 o s T

35 s d m n 36 E 6

a x 37 s u O

38 h n T i ( 39 2 e

40 g n

41 a - h

42 C 2005 2010 2015 2018 43 44

218 In Figure ___ below, the bars labeled “10/20 goals” represents the policy scenario with the 10/20 goals, “EE” 3represents the policy scenarios with the energy efficiency recommendations and “EE + 10/20 goals” represents the 4policy scenario with both the 10/20 goals and the energy efficiency recommendations. 5 619 MTF 2000.

1 2 A secondary environmental benefit of implementating the 10/20 goals and energy 3efficiency recommendations is the reductions in CO2 emissions. CO2 emissions savings in 2018 4are estimated to range between 40 million metric tones and 55 million metric tones (or 10 5percent to 14 percent relative to the BAU scenario). 6 7 8Energy Costs Impacts 9 10 Meeting the 10/20 renewable energy goals would increase annual levelized electricity 11production costs in the region by an estimated $300 million, a 2 percent increase above a 12business-as-usual scenario. 20 Implementing the Forum’s efficiency measures would save the 13region roughly $1 billion annually. Together, relative to business-as-usual scenario, meeting the 1410/20 goal and implementing the efficiency measures would reduce annual levelized electricity 15production costs in the region by approximately $700 million. 16 17 Figure ___ compares the electricity production cost between the business-as-usual and 18energy efficiency-only scenarios; and business-as-usual and the energy efficiency plus renewable 19energy policy scenario. 20 21 22 23 Figure___: Annual Levelized Production Cost Under the BAU and Energy Efficiency Policy Scenarios 24

) $20 $ 1 0

0 $17.4 2 $16.4 $16.7 n o i l l i

B $15 (

s t s o C

n o i t $10 c u d o r P

d e z i

l $5 e v e L

l a u n n $0 A 25 BAU EE EE + 10/20 Goals 26 27 28 In addition, Implementation of both the 10/20 goals and energy efficiency 29recommendations will reduce demand and expenditures for natural gas in the region by nearly $2 30billion annually. This also serves to provide some security benefits against increases in 31electricity costs due to natural gas price increases and supply shocks.

2 20 The $300 million cost increase reflects the assumption that renewable energy technology will improve over time, 3 which the AP2 Forum believes to be the most likely scenario. To provide an an upper bound estimate of 4 the potential cost increase resulting from achieving the 10/20 goals the Forum also asked ICF to model a scenario 5 in which renewable energy costs remain at today's levels and do not improve over time. Under this scenario the 6 annual production costs of meeting the 10/20 goals increased to $900 million. 7

1Secondary Regional Economic Impacts 2 3 The results of the regional economic analysis indicate that the 10/20 goals and energy 4efficiency may, on average, lead to an increase in economic activity. Over time, the policies lead 5to small increases in economic activity in the early years a small decline in later years. The 6impacts in the 2005 to 2015 time period are largely the result of investment in new renewable 7energy facilities that increase labor demand and have secondary impacts on output and income. 8 9 10Table 1: Annual Average (2005 – 2020) Changes In Key Economic Indicators for the Transport Region Under the 11Policy Scenarios 12 Employment Gross Regional Product Personal Disposable Income 13 (Persons) (% Change) (Million 2001$) (% Change) (Million 2001$) (% Change) 10/20 Goals 627 0.00% -312 -0.01% 73 0.00% Energy Efficiency (EE) 8,415 0.02% 450 0.02% 776 0.04% 10/20 Goals + EE 4,097 0.01% -58 0.00% 547 0.03% 14 Following the investment and construction boom, the region will see some decline in 15employment, gross regional product and personal disposable income. 16 17 On average, the 10/20 goals will lead to small increases in employment and personal 18income along with a small decline in gross regional product. Implementation of the energy 19efficiency recommendations results in small increases in employment, personal disposable 20income and gross regional product. The boom in construction sparked by the investments 21appears to be the key reason for growth. 22 23 24Conclusions of Modeling Results 25 26 The analysis indicates that the 10/20 goals and energy efficiency recommendations could 27both serve as cost-effective air pollution prevention strategies. The 10/20 goals will lead to 28increases renewable energy capacity, while the energy efficiency recommendations will result in 29lower energy demand through conservation. Because both the 10/20 goals and energy efficiency 30displace new additions of fossil fuel capacity and generation, they are likely to provide a hedge 31against future emissions growth in NOx and CO2. The 10/20 goals can be achieved under modest 32cost impacts, while energy efficiency will result in some cost savings and both the objectives 33have little or no regional economic impacts.

1 Recommendations of the Air Pollution Prevention Forum 2 3 The Air Pollution Prevention Forum recommends that the WRAP endorse the following 4recommendations of the Forum and forward such recommendations to the states and tribes in the 5Transport Region for their consideration. 6 7 8Renewable Energy Policies for States and Tribes 9 10 The AP2 Forum recommends states and tribes in the Transport Region take the following 11actions to promote development and use of renewable energy. 12 13 1. Adopt a Renewable Portfolio Standard or a “non-bypassable” Systems Benefit Charge 14 applied to electricity sold, or both, as “core” financial incentives to promote the use of 15 renewable energy sources. 16 17 Due to existing costs and institutional barriers State and federal financial incentives will 18 be necessary to achieve the 10/20 goals. Financial incentives: should be provided on a 19 competitive basis; should be of sufficient duration to provide certainty to investors in 20 renewable energy projects; and should not discriminate against out-of-state renewable 21 energy generation. 22 23 2. Implement tax incentives to encourage renewable energy development. 24 25 State tax policies that can promote increased investment in renewable energy 26 technologies include production tax credits, personal and corporate income tax credits, 27 property tax incentives and sales tax exemptions from purchases of renewable energy 28 equipment and electricity. 29 30 3. Require utilities to offer customers the choice of purchasing electricity generated from 31 renewables and the option to choose other “green” products and services 32 33 34 Market research and early experience with green power marketing and utility sponsored 35 green pricing programs shows a significant number of electricity customers are willing 36 to pay a premium to purchase electricity generated from renewable energy. 37 38 4. Adopt information disclosure rules and power labels on utility bills that provide 39 consumers with accurate information on the price, source of power, and environmental 40 attributes of their electricity supply. 41 42 Consumer research and experience from states with retail competition indicate consumer 43 choice is strongly influenced by the price, resource mix, and environmental impacts of 44 power supplies in an electric service providers portfolio. For green power markets and 45 green pricing programs to operate efficiently and be effective in increasing demand for 46 renewable energy, consumers need access to accurate and consistent information about

1 their electricity supply. Efforts to institute labeling and disclosure rules should be 2 coupled with consumer education programs. 3 4 5. Establish a generation tracking system in concert with other states, tribes, regional 5 electricity reliability entities and/or regional transmission organizations. 9 10 11 A generation tracking system for the entire western interconnected system will provide 12 verification of information needed to ensure consumer confidence in the information on 13 power labels, protect “green power” consumers from electricity from the resale of 14 renewable energy, facilitate monitoring compliance with state RPS’, and verification and 15 certification of renewable energy certificates. 16 17 6. Develop policies that eliminate transmission and distribution system barriers that hinder 18 consumer access to renewable energy supplies, products, and services. 19 20 State transmission and distributions system policies should: 1) support uniform 21 interconnection standards to remove interconnection barriers and allow for the fair and 22 safe interconnection of renewable energy facilities to the electric grid; 2) support 23 transmission protocols being developed by regional transmission organizations that do 24 not penalize intermittent renewable resources; and 3) allow net metering for renewable 25 energy technologies at the customer’s meter. 26 28 29 7. Opt in to the Section 309 regional SO2 “cap-and-trade program”, as outlined in the 30 Annex, under the Regional Haze Rule 31 8. . 32 33 34 States should opt into the Section 309 regional SO2 cap-and-trade program to limit 35 regional SO2 emissions and create a market in which emission credits can be bought and 36 sold. Such a market puts a monetary value on SO2 emissions and provides an economic 37 incentive to engage SO2 reducing activities such as investments in renewable energy. 38 39 8. Establish policies and processes to improve the siting of renewable energy generation 40 facilities. 41 42 States and tribes should improve siting processes for renewable energy facilities 43 including: 1) training for regulators on land use and environmental issues surrounding 44 the siting of renewable energy facilities; 2) creating a process to enable government 45 decision makers in a jurisdiction which has considered a renewable energy facility siting 46 application to share their experience and lessons learned with other jurisdictions 47 considering applications for similar projects; and 3) coordination between states and 48 tribes in siting review processes, including resolution of jurisdictional issues for projects 49 that involve both state and tribal lands. 50

1 9. Support creation of a single institution in the Western Interconnection to register, certify, 2 and oversee trading of renewable energy certificates in the West.21 3 4 Environmental attributes of electricity generated from renewable sources have economic 5 value and can be sold separately from the electricity as renewable energy certificates 6 (RECs). Selling of RECs represents a market based-strategy that improves the 7 economics, overcomes transmission barriers, and provides consumers access to the most 8 economic renewable energy resources. In combination with other policies recommended 9 by the AP2 Forum, RECs can contribute to accelerating development of the West’s most 10 promising renewable resources. 11 12 10. Endorse cooperative actions and complementary efforts by the federal government to 13 promote the development of renewable energy that do not undermine historical 14 authorities of the states. 15 16 Complementary action by the federal government is needed to achieve the 10/20 goal 17 because of the significant presence of the federal government in the WRAP region. 18 Actions states should consider supporting include funding for research, development and 19 commercial demonstration of near competitive renewable technologies, a national 20 renewable portfolio standard, extension of the existing federal production tax credit 21 (FPT) for wind and biomass through 2015 and broadening the credit to include 22 geothermal, development of other tax incentives, and mandatory federal agency 23 renewable energy purchase requirements. 24 25 26Additional Renewable Energy Policies Specifically for Tribes 27 28 When appropriate, tribes may wish to implement some or all of the renewable energy 29recommendations presented above. Due to the diversity of the tribes and their unique 30circumstances, the Forum recommends tribes consider the following additional 31recommendations. Tribes may best implement some of these recommendations individually, 32while others may be more appropriate as collaborative efforts with other tribes, states, or the 33federal government. 34 35 1. Develop a tribal energy policy 36 37 A formal energy policy statement that incorporates specific provisions for renewable 38 electric energy is an important beginning to a larger set of strategies. A program to 39 stimulate renewable energy generation will be most effective as part of a more 40 comprehensive energy policy developed by and adapted to each tribe. 41 42 43

221 Western governors support the renewable energy certificates as a market based strategy to support the 3development of renewable energy in the western interconnect. See WGA Policy Resolution 02-26, section (B)(4) 4(c), pg. 4-5.

1 2 2. Develop renewable energy resources 3 4 Virtually every tribe in the WRAP region enjoys an abundance of renewable energy 5 resources. Tribes with an established tribal electric utility are already well positioned to 6 expand the role of that utility to develop viable sources of renewable energy. The AP2 7 Forum encourages tribal utilities to consider exploring these opportunities. Other tribal 8 governments that lack the infrastructure of an existing utility might consider establishing 9 such an enterprise. 10 11 3. Initiate energy training and education programs 12 13 The Forum recommends that all consumers have the opportunity to select the purchase 14 of energy supplies from renewable sources. Tribal implementation of this 15 recommendation may include consumer education programs addressing purchasing 16 options and their associated environmental impacts. 17 18 4. Create an Economic Development Corporation 19 20 Tribes that choose to pursue a renewable energy enterprise may consider setting up a 21 tribal Economic Development Corporation (EDC). Tribes with an EDC or comparable 22 entity already in place may utilize it to advance the opportunities for entrepreneurial 23 energy development. The somewhat autonomous role of an EDC has been shown to be 24 useful when pursuing a long-term economic development initiative such as required for 25 most energy projects. 26 27 5. Purchase electricity generated by renewable sources 28 29 Tribal governments could demonstrate leadership in renewable energy advocacy through 30 the purchase of electricity from renewable energy suppliers as part of their tribal energy 31 policy. 32 33 6. Expedite the permitting process for renewable energy projects 34 35 Tribal governments could streamline the permitting process for renewable energy 36 projects located within their jurisdiction. Such a process will encourage rather than 37 discourage innovative energy supply and distribution enterprises. 38 39 7. Multi-party renewable energy actions for on-reservation programs 40 41  Renewable energy programs at federal facilities – There are many federal 42 facilities on tribal lands. Tribal governments could consider requiring that such 43 federal facilities comply with a tribal energy policy that stipulates the purchase of 44 electricity from a renewable energy supplier, including the tribal utility where 45 applicable. 46

1  Federal financing of authorized renewable energy assistance – Several federal 2 statutes authorize funding for energy conservation and renewable energy incentives 3 on tribal lands. Most notable is the Energy Policy Act of 1992 and its amendments. 4 Tribal leaders could formally request adequate appropriations from the U.S. 5 Congress and appropriate agencies to implement the energy conservation and 6 renewable energy development provisions of these laws. This should include funding 7 of training programs for tribal energy professionals related to renewable energy and 8 energy efficiency. 9 10  Federal project grants and subsidies – One federal mechanism to encourage 11 private sector development and use of renewable energy is tax credits. Because this 12 mechanism is of little use to most tribes, tribes may request equivalent federal 13 financial subsidies for tribal renewable energy projects (for example, a tribal energy 14 block grant). 15 16  Utilize tribal SO2 and renewable energy emissions allowances – Referring to the 17 “cap-and-trade” program mentioned earlier, the Forum recommends that tribes 18 consider seeking allowances under this program to encourage renewable energy 19 generation on tribal lands through both the tribal set-aside allocation and the 20 renewable energy set aside allocation. 21 228. Tribal leadership in renewable energy activities beyond tribal lands 23 24  Develop a Tribal Implementation Plan – Consider developing a Tribal 25 Implementation Plan under the provisions of the Regional Haze Rule and the Tribal 26 Authority Rule that commits the tribe to expanding its use of renewable energy in the 27 generation and use of electricity. 28 29  Develop inter-tribal energy collaborations – Some renewable energy development 30 opportunities require resources beyond those available to small tribal populations 31 and lands. The Forum recommends that small tribes consider expanding existing 32 intertribal relationships and forging new ones where renewable energy development 33 projects exceed the capacity of an individual tribal government. 34 35  Secure tribal authority over non-Indian lands within reservation boundaries – 36 For many tribes an effective energy policy, including full development of renewable 37 energy resources, will depend on tribal authority over all lands within reservation 38 boundaries, which can include non-Indian lands. The Forum recommends that tribes, 39 federal agencies, and states, as appropriate, enter into agreements that recognize 40 such tribal authority for the purpose of development and implementation of 41 renewable energy policies and practices. 42 43  Encourage creating a federal renewable portfolio standard – Tribal governments 44 could support a national renewable portfolio standard. 45

1  Expand federal government’s “Buy Indian” policy – The “Buy Indian” policy is 2 advantageous to suppliers of selected products and services that are purchased by 3 specific federal agencies. The Forum recommends 1) that this policy be expanded to 4 include the purchase of electricity generated from renewable sources on tribal lands, 5 and 2) that the participating agencies be expanded to include all relevant federal 6 energy procurement. 7 8  Expand the federal government’s program for procurement of green energy – 9 Tribes may consider requesting that the Federal government encourage Power 10 Marketing Agencies to obtain electricity generated from renewable resources on 11 tribal lands, combined with the Federal government programs in Executive Order 12 13123 for the Federal Government’s procurement of green energy. A portion of the 13 electricity generated from these renewable resources could be made available for 14 tribal use, similar to hydropower electricity made available from the Western Area 15 Power Administration. 16 17  Encourage federal tax credits for renewable generation – As discussed previously, 18 the Forum recommends that tribes consider engaging in the preferential procurement 19 of electricity from suppliers of renewable energy. Concurrently, private sector 20 suppliers of renewable energy, in response to these policies, should be awarded 21 appropriate federal tax credits. This practice will stimulate short-term competitive 22 pricing while limiting financial penalties to both purchasers and providers. 23 24  Create partnerships with Independent Power Producers – Tribal governments 25 seeking to develop renewable resources may find it desirable to collaborate with an 26 Independent Power Producer to expedite resource development and to limit tribal 27 financial exposure. 28 29  Explore state-tribal agreements for renewable energy projects on tribal lands – 30 Some tribes may want to explore with states the possibility of a state-tribal agreement 31 for renewable energy projects on tribal lands as part of a state’s strategy to meets its 32 own 10/20 goal for renewable energy. 33 34 35Energy Efficiency Policies for States and Tribes 37 38 The Air Pollution Prevention Forum recommends that states and tribes in the Transport 39Region: 40 41 1. Adopt policies that provide ratepayer funding to support utility and/or State sponsored 42 demand-side energy efficiency programs. 43 44 Increasing the penetration of energy efficiency and conservation in the region can best 45 be accomplished through state policies that provide funding to utility or State sponsored 46 demand side energy efficiency programs supported by ratepayers, and whose costs are

1 included in rates or appear separately on customer bills as a “tariff rider” or a systems 2 benefits charge. 3 4 2. Develop complimentary tax incentives to promote investments in energy efficiency and 5 conservation by residential consumers and businesses. 6 7 Complementary tax incentives include income tax credits, and sales tax exemptions for 8 investments in high efficiency applicances, equipment, designs and services. 9 10 3. Support minimum efficiency standards for appliances, equipment, and buildings. 11 12 Minimum energy efficiency standards can be very effective strategies for transforming 13 the region’s economy to be more energy efficient. While states are free to develop 14 energy standards for buildings, they are preempted by federal law from developing state 15 standards for equipment covered by the federal appliance standards program, unless 16 they apply to and receive a waiver from the U.S. Department of Energy. The increasing 17 prevalence of electronic devices and expanding digital economy, coupled with the West’s 18 hot dry climate that causes a substantial peak in summer demand, provides an important 19 opportunity for the region to develop “regional” efficiency standards for electronic 20 devices, air conditioning and other appliances and equipment that impact summer peak. 21 22 4. Implement utility rate reforms that send accurate price signals to consumers. 23 24 Implementation of utility rates structures such as real-time, time of use, inclined block, 25 and other pricing approaches more effectively communicate the cost of electricity (and 26 gas) supply to consumers and provide market-based price incentives to reduce electricity 27 consumption. 28 29 5. Participate in regional market transformation programs to increase access and availability 30 of energy efficient equipment, appliances and practices in the market place. 31 32 Market transformation programs are designed to bring about lasting change in 33 consumer behavior and increase access and availability of energy efficient equipment, 34 appliances and practices in the market place. States in the Transport Region can effect 35 lasting change by participating in regional market transformation programs similar in 36 scope to the successful horizontal axis washing machine program promoted in the 37 Pacific Northwest. 38 39 6. “Lead-By-Example”. 40 41 The public sector can create “market pull” for energy efficient products and services in 42 states and the region by adopting policies that improve energy efficiency of public 43 buildings and support energy efficient management practices and procurement. 44 Specifically, states should develop a comprehensive public buildings efficiency plan, 45 including mandatory efficiency standards for state and municipal new construction; 46 public building retrofit programs employing performance contracting as appropriate;

1 life-cycle cost procurement standards for energy-using equipment and systems; and train 2 building operation and maintenance staff in retro-commissioning to ensure public 3 buildings energy systems are operated to maximize performance and efficient use of 4 energy. 5 6 7. Modify environmental regulatory approaches to create opportunities for energy efficiency 7 improvements to be counted as pollution control measures for criteria pollutant SIPs. 8 9 State air quality officials can investigate how to modify their regulatory approach to 10 create opportunities for energy efficiency improvements to be counted as pollution 11 control measures that provide “measurable, verifiable, and permanent” emissions 12 reductions within the regulatory framework provided by the CAAA for criteria pollutant 13 SIPs.22 14 15 16Additional Energy Efficiency Policies Specifically for Tribes 17 18 Tribes may wish to implement some or all of the energy efficiency recommendations for 19states as presented above. The Forum recognizes the unique and special circumstances of many 20tribes, and submits the following additional recommendations for tribes to consider. Some of 21these recommendations may best be implemented by individual tribes, while others are suitable 22for collaborations with other tribes, states, or the federal government. 23 24 1. Development of an energy plan 25 26 For tribes that do not have one, the Forum recommends that tribes consider developing 27 an energy plan or policy. Establishing an energy plan is the first necessary step in 28 gaining control over the energy use and costs incurred by a tribe. The plan can enhance 29 tribal sovereignty and energy independence. 30 31 2. Tribal energy manager 32 33 For tribes without an energy manager, the Forum recommends such a position be 34 established. An energy manager within an energy authority can direct and manage 35 energy programs including those related to energy efficiency. The energy manager can 36 also recommend policies for consideration by the tribal council. For tribes without an 37 energy authority, an energy manager position can be created elsewhere within the tribal 38 government. 39 40 3. Tribal energy authority 41 42 Tribes without an energy (utility) authority might consider establishing such an entity 43 (either individually or in collaboration with other tribes). Perhaps the most important 44 recommendation to tribes concerning energy efficiency is that of designing a tribal

222 Western Governor’s Policy Resolution 02-26, section (4)(g)(viii) page 7, calls for western states and tribes to 3“develop mechanisms to encourage energy efficiency measures in air quality planning documents.”

1 energy plan that is managed by an energy manager within a tribal energy authority. A 2 tribal energy authority also has the effect of improving a tribe’s sovereignty and 3 promises improved self-determination. 4 5 4. Establish energy-conserving building codes and incorporate them into new construction 6 and building renovations 7 8 As new buildings are constructed and older buildings are renovated, there is a great 9 opportunity for energy savings by employing energy-efficiency methods. Tribes can 10 adopt energy-efficient building codes such as the International Energy Conservation 11 Code. It is also recommended that energy efficiency be integrated into housing plans, 12 and that life cycle cost methods be used when evaluating the energy systems within 13 buildings. 14 15 5. Electrification expansions 16 17 With new electrification comes the opportunity to implement energy efficiency. New 18 customers in rural areas may spend a large fraction of their monthly income on energy, 19 in some cases as much as 20 percent. In these cases it is critical that cost-effective, 20 energy-efficient appliances and building materials be employed. 21 22 6. Education programs 23 24 Education can make the difference between an effective, successful, comprehensive 25 energy management program and a fragmented program with little support. Educating 26 tribal members, leaders, facility managers, staff members, and contractors about the 27 benefits of monitoring and conserving energy will build support for an energy program 28 and will lead to significant savings in energy costs. 29 30 7. Tribal Implementation Plan 31 32 A Tribal Implementation Plan under the provisions of the Regional Haze Rule and the 33 Tribal Authority Rule would commit the tribe to developing an energy plan and to 34 employing energy efficiency as a method to reduce electricity consumption. Such a plan 35 would be a good step toward tribal energy conservation 36 . 37 8. Intertribal collaborations 38 39 Many tribes may lack the resources to establish their own energy authority or even to 40 hire their own energy manager. In these cases it may be beneficial to initiate 41 partnerships with other tribes for that purpose. Beyond this, tribes could work 42 collaboratively to encourage the federal government, through its trust responsibility, to 43 fund energy-efficiency programs (including education programs and rebate programs) 44 and to provide funding to tribes for energy management. 45 46

1 2 9. Federal facilities 3 4 There are numerous federal facilities on tribal lands, and these facilities consume an 5 appreciable amount of electrical energy. Tribes could adopt energy conservation policies 6 that require federal facilities on tribal lands to meet modern energy-efficiency codes such 7 as the International Energy Conservation Code. 8 9 10. Federally sponsored programs 10 11 There are several federally sponsored programs in which tribes may participate to 12 implement energy efficiency. These programs include the Weatherization Assistance 13 Programs (WAP) and the DOE Rebuild America Program. The forum recommends that 14 tribes, as part of their overall energy plan, participate in existing federally sponsored 15 programs related to energy efficiency. Tribes may also consider requesting funding for 16 efficiency programs from the federal government via several existing statutes. This could 17 include funding of training programs for tribal energy professionals related to renewable 18 energy and energy efficiency. 19 20 11. Tribal leadership beyond tribal lands 21 22 The mitigation of haze throughout the West will depend upon all users of electricity and 23 other energy forms that impact haze. Thus, tribes may consider supporting demand-side 24 management programs and national energy efficiency policies and standards.

1 Appendix I 2 3 EPA Regional Haze Rule Section 51.309(d)(8) 4 Pollution Prevention 5 6 7 8 The plan must provide for: 9 10(i) An initial summary of all pollution prevention programs currently in place, an inventory of all 11renewable energy generation capacity and production in use, or planned as of the year 2002 12(expressed in megawatts and megawatt-hours), the total energy generation capacity and 13production for the State, the percent of the total that is renewable energy, and the State’s 14anticipated contribution toward the renewable energy goals for 2005 and 2015, as provided in 15§51.309(d)(8)(vi). 16 17(ii) Programs to provide incentives that reward efforts that go beyond compliance and/or achieve 18early compliance with air-pollution related requirements. 19 20(iii) Programs to preserve and expand energy conservation efforts. 21 22(iv) The identification of specific areas where renewable energy has the potential to supply 23power where it is now lacking and where renewable energy is most cost-effective. 24 25(v) Projections of the short- and long-term emissions reductions, visibility improvements, cost 26savings, and secondary benefits associated with the renewable energy goals, energy efficiency 27and pollution prevention activities. 28 29(vi) A description of the programs relied on to achieve the State's contribution toward the 30Commission's goal that renewable energy will comprise 10 percent of the regional power needs 31by 2005 and 20 percent by 2015, and a demonstration of the progress toward achievement of the 32renewable energy goals in the years 2003, 2008, 2013, and 2018. This description must include 33documentation of the potential for renewable energy resources, the percentage of renewable 34energy associated with new power generation projects implemented or planned, and the 35renewable energy generation capacity and production in use and planned in the State. To the 36extent that it is not feasible for a State to meet its contribution to the regional renewable energy 37goals, the State must identify in the progress reports the measures implemented to achieve its 38contribution and explain why meeting the State's contribution was not feasible.

1 2 Appendix II 3 4 Membership of the Air Pollution Prevention Forum 5 6 7Robert “Hap” Boyd, GE Wind, Co-Chair 8Jeff Burks, Utah Energy Office, Co-Chair 9Bill Becker, U.S. Department of Energy 10Trisha Frank, Manzanita Tribe 11Rich Ferguson, Center for Energy Efficiency and Renewable Technologies 12Bob Green, Kennecott 13Brian Hedman, Quantec, Inc. 14Van Jamison, PowerAir Consulting 15Ursula Kramer, Pima County DEQ 17John Nielsen, Land and Water Fund of the Rockies 18Terry O’Connor, Arch Mineral, Inc. 19Stan Price, Northwest Energy Efficiency Coalition 20John Savage, Oregon Department of Energy 21Rachel Shimshak, Renewable Northwest Project 22Rich Sperberg, Onsite Sycom Energy Corp 23Julie Simpson, Nez Perce Tribe 24Barrett Stambler, Pacific Power Marketing 25Dick Watson, Northwest Power Planning Council 26Chris Wentz, New Mexico Energy Office 27Alan Davis, Montana Department of Environmental Quality 28Cynthia Praul, California Energy Commission 29Steve Ellenbecker, Wyoming PUC 30Amanda Ormond, Arizona Energy Office/Ormond Group 31Tom Hines, Arizona Public Service 32Virinder Singh, PacifiCorp

1 Appendix III 2 3 Meetings of the Air Pollution Prevention Forum 4 5 61) August 12-13, 1999, Denver, Colorado 7 First meeting of the Forum 8 Overview of: regional haze rule, the charge to the forum, and the WRAP 9 102) November 8-9, 1999, Scottsdale, Arizona 11 Presentations from panel of experts on renewable energy 12 Adopted working definition of renewable resources 13 143) January 31 – February 1, 2000, San Diego, California 15 Reviewed first draft of Sections A and B of Renewables Report 16 Discussion on what should be covered in sections C and D 17 184) March 13-14, 2000, Portland, Oregon 19 Reviewed first draft of full report 20 Made changes and modifications, set deadline for comments 21 225) May 31 – June 1, 2000 , San Francisco 23 Efficiency scoping 24 Examined changes in the demographics and economy in the WRAP region 25 including growing demand for electricity and internet issue 26 276) October 2, 2000, Denver, Colorado 28 “Brainstorming” meeting on modeling and energy efficiency 29 307) December 5-6, 2000, Portland, Oregon 31 Developed outline for Energy Efficiency Report 32 Assignments for sections of the report 33 Created quantification work group to oversee modeling 34 358) March 15-16, 2001, Sacramento, California 36 Reviewed write-ups for best energy efficiency practices 37 Discussed SIP guidebook 38 Presentation on tribal renewable and energy efficiency reports 39 409) November 5-6, 2001, Denver, Colorado 41 Quantitative work group meeting 42 SIP guidebook work group 43 4410) February 19-20, 2002, Denver, Colorado 45 Review modeling results 46 Discuss report to be delivered to WRAP 47 4811) June 5-6, 2002, Portland, Oregon 49 Discuss final modeling results 50 Comments on draft final report

1 Appendix IV 2 3 Reports of the Air Pollution Prevention Forum 4 5 6Final Report on Energy Efficiency and Renewable Energy, Prepared by the Air Pollution 7Prevention Forum for the Western Regional Air Partnership, January 2002. 8 9Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency 10Recommendations, Draft Report, prepared by ICF Consulting for the Air Pollution Prevention 11Forum, October 2002 12 13Reducing Energy Consumption and Improving Air Quality through Energy Efficiency in Indian 14Country: Recommendations to Tribal Leaders from the Western Regional Air Partnership, 15November 2002 16 17Recommendations for the Western Regional Air Partnership’s Air Pollution Prevention Forum 18to Increase the Generation of Electricity from Renewable Resources on Native American Lands, 19Draft Report, April 2002 20 21Recommendations of the Air Pollution Prevention Forum to Increase Energy Efficiency and 22Conservation in the GCVTC States, (forthcoming) 23 24Draft Background Report: Identification and Analysis of “Best” Energy Efficiency Measures 25and Practices for the West, prepared by the Air Pollution Prevention Forum, September 1, 2001. 26 27Discussion Paper: Scoping the Energy Efficiency Work of the Air Pollution Prevention Forum, 28prepared for the Air Pollution Prevention Forum by WIEB staff, September 30, 2000. 29 30Recommendations of Air Pollution Prevention Forum To Increase the Generation of Electricity 31from Renewable Resources, June 30, 2000

1 APPENDIX V 2 3 Renewable Energy Programs and Policies

1 Appendix VI 2 3 AP2 Forum’s Selected Energy Efficiency “Best Practices”23 4 5Interior West -- Residential Sector

223 Demand Side Management Type Programs Except where Indicated

Major Option Types of Measures Efficient cooling systems Evaporative cooling – installation, retention and renewal of systems Appliance recycling Removal of older refrigerators and freezers Efficient lighting Mix of compact fluorescent lamp based measures Appliance standards ** Clothes washers – mix of Energy Star vertical axis machines and horizontal axis machines Appliance standby loss – reduce loss to one watt per electronic device Building thermal performance Weatherization – existing buildings

1 2Interior West -- Commercial Sector

Major Option Types of Measures Efficient lighting Mix of better technologies Efficient refrigeration Mix of better technologies Efficient cooling systems Cooling efficiency – mix of better systems Indirect/direct evaporative cooling Efficient space heating system Ground source heat pump Fuel switching from electric to gas Multi-measure strategies for Miscellaneous devices (LED traffic lights and signs, clothes washers, existing building stock computers, monitors and other office electronics) Retro-commissioning Operations and maintenance of existing building stock Water heating Mix of efficiency and fuel switching from electric Transformers Efficiency improvements

1 2Interior West -- Industrial Sector

Major Option Types of Measures Transformers Efficiency improvements Motors Premium motors (including replace rather than rewind) and motor downsizing Motor drive systems System upgrades of fans, air compressors, pumps

1 1Oregon / w. Idaho -- Residential Sector Major Option Types of Measures Efficient cooling systems Evaporative cooling – installation, retention and renewal of systems Appliance recycling Removal of older refrigerators or freezers Efficient lighting Mix of compact fluorescent lamp–based systems Appliance standards** Clothes washers – mix of energy star vertical axis machines and horizontal axis machines Appliance standby loss – reduce loss to 1 watt per electronic device 1 2 3 4 5 6Oregon / w. Idaho -- Commercial Sector Major Option Types of Measures Efficient lighting Mix of better technologies Efficient refrigeration Mix of better technologies Efficient cooling systems Cooling efficiency – 20 ton package units

Efficient space heating system Ground source heat pump Fuel switching from electric to gas Multi-measure strategies for Miscellaneous devices (LED traffic lights and signs, clothes washers, existing building stock computers, monitors and other office electronics) Retro-commissioning Operations and maintenance of existing building stock Water heating Mix of efficiency and fuel switching from electric Transformers Efficiency improvements 7 8Oregon / w. Idaho -- Industrial Sector Major Option Types of measures Transformers Efficiency improvements Motors Premium motors (including replace rather than rewind) and motor downsizing Motor drive systems System upgrades of fans, air compressors, pumps Aluminum process Retrofit options to improve efficiency of cells (reduce anode-cathode improvements spacing) and reduce heat loss 9 10California/Las Vegas -- All Sectors Major Option Types of measures System benefit fund Demand-side management for lighting, appliances, air conditioning, motor systems, other Equipment efficiency Distribution transformers, commercial refrigeration, exit signs and traffic standards** lights, torchieres, commercial unit heaters, air conditioners, ice makers, residential refrigerators, dishwashers, standby loss reduction Tax incentives for efficiency** Clothes washers, refrigerators, air conditioning, gas heat pumps, heat pump water heating, furnaces, efficient new construction (residential and commercial) 11 12 13

1 Appendix VII 2 3 Cost Of Saved Energy Results Sorted By Cost Per kWh: 4 5 6 Percent of Percent of Real Levelized Total Total Discounted Cost of Saved Cummul. Cummulative Cummul. Cummulative TRC Cost MWh Savings Energy Package MWh Savings Package Discounted Measure ($1000) Through 2026 ($/kWh) Savings through 2026 Costs TRC Cost Residential Evaporative Cooling $ (111,017) 5,007,946 $ (0.0489) 1.7% 5,007,946 -4.4% $ (111,017) Residential IDDEC Cooling $ (15,554) 2,305,001 $ (0.0151) 2.5% 7,312,947 -5.0% $ (126,571) Comml/Instit. Space Heat Std. Gas Boiler $ (458) 465,659 $ (0.0022) 2.6% 7,778,606 -5.0% $ (127,029) Comml/Instit. Space Heat High Eff. Gas Boiler $ (565) 962,327 $ (0.0013) 3.0% 8,740,933 -5.1% $ (127,594) Comml/Instit. Water Heat Gas Boiler Fuel Switch $ (1,145) 3,325,686 $ (0.0008) 4.1% 12,066,619 -5.1% $ (128,739) Comml/Instit. Water Heater Fuel Switching $ (505) 3,484,222 $ (0.0003) 5.3% 15,550,841 -5.1% $ (129,244) Comml/Instit. Space Heat Gas Unit Heater $ 422 803,719 $ 0.0011 5.6% 16,354,560 -5.1% $ (128,821) Industrial Fan System Measures $ 7,041 2,473,382 $ 0.0062 6.4% 18,827,942 -4.8% $ (121,780) Industrial Air Compressor System Measures $ 23,789 8,347,664 $ 0.0062 9.2% 27,175,606 -3.9% $ (97,991) Residential CFL Torchiere $ 62,045 21,232,172 $ 0.0067 16.5% 48,407,778 -1.4% $ (35,946) Industrial Motor Downsizing $ 3,416 865,684 $ 0.0086 16.8% 49,273,462 -1.3% $ (32,531) Comml/Instit. Refrigeration, Low-cost Measures $ 29,224 6,446,877 $ 0.0098 19.0% 55,720,339 -0.1% $ (3,307) Residential CFL Bulbs $ 49,797 8,999,064 $ 0.0099 22.0% 64,719,403 1.8% $ 46,490 Comml/Instit. Water Heating, Heat Pump Unit $ 4,169 833,390 $ 0.0106 22.3% 65,552,793 2.0% $ 50,659 Comml/Instit. LED Exit Signs $ 10,551 2,212,350 $ 0.0109 23.1% 67,765,143 2.4% $ 61,210 Comml/Instit. Lighting, Efficient Fluorescent $ 120,842 22,406,144 $ 0.0117 30.7% 90,171,287 7.2% $ 182,052 Residential CFL Fixtures--Indoor $ 24,370 4,477,776 $ 0.0124 32.2% 94,649,063 8.2% $ 206,422 Industrial Premium Motors $ 32,469 4,640,110 $ 0.0137 33.8% 99,289,173 9.5% $ 238,891 Residential Appl. Standby Loss Red.--Mandatory $ 186,808 31,092,432 $ 0.0138 44.4% 130,381,605 16.9% $ 425,699 Residential Appl. Standby Loss Red.--Incentive $ 19,091 2,018,494 $ 0.0148 45.1% 132,400,099 17.7% $ 444,789 Comml/Instit/Industrial Transformers (C/I) $ 14,260 1,903,312 $ 0.0172 45.7% 134,303,411 18.2% $ 459,050 Industrial Pump System Measures $ 130,051 15,459,078 $ 0.0183 51.0% 149,762,489 23.4% $ 589,101 Comml/Instit. Retrocommissioning $ 35,765 4,203,554 $ 0.0186 52.4% 153,966,043 24.8% $ 624,866 Comml/Instit. Refrigeration, High-cost Measures $ 30,151 3,487,028 $ 0.0188 53.6% 157,453,071 26.0% $ 655,018 Residential Appliance Recycling $ 40,598 2,593,122 $ 0.0204 54.5% 160,046,193 27.6% $ 695,616 Comml/Instit/Industrial Transformers (Industrial) $ 2,150 223,428 $ 0.0220 54.6% 160,269,621 27.7% $ 697,766 Residential CFL Fixtures--Outdoor $ 5,562 515,112 $ 0.0228 54.7% 160,784,733 27.9% $ 703,328 Comml/Instit. AC Impr., 20-ton Package Units $ 296,085 28,046,667 $ 0.0236 64.3% 188,831,400 39.7% $ 999,414 Comml/Instit. Ground-source HP, 3000 hrs/yr $ 30,955 2,745,355 $ 0.0249 65.2% 191,576,755 40.9% $ 1,030,369 Comml/Instit. Lighting, Advanced Measures $ 795,012 64,744,193 $ 0.0266 87.2% 256,320,948 72.4% $ 1,825,380 Comml/Instit. AC Impr., Residential-type CAC $ 57,876 4,042,410 $ 0.0307 88.6% 260,363,358 74.7% $ 1,883,257 Comml/Instit. LED Traffic Signals $ 13,697 931,600 $ 0.0322 88.9% 261,294,958 75.3% $ 1,896,954 Comml/Instit. Efficient Clothes Washers $ 15,511 914,946 $ 0.0335 89.2% 262,209,904 75.9% $ 1,912,465 Comml/Instit. AC Impr., Small Heat Pump $ 93,753 5,867,466 $ 0.0343 91.2% 268,077,370 79.6% $ 2,006,218 Comml/Instit. Ground-source HP, 2000 hrs/yr $ 30,955 1,830,237 $ 0.0373 91.9% 269,907,607 80.9% $ 2,037,173 Comml/Instit. AC Impr., Res. Room-type AC $ 66,814 3,738,494 $ 0.0383 93.1% 273,646,101 83.5% $ 2,103,987 Residential Weatherization $ 109,264 5,824,614 $ 0.0402 95.1% 279,470,715 87.8% $ 2,213,251 Comml/Instit. Gas AC, w/ heat recov. (EWH) $ 53,763 2,896,170 $ 0.0420 96.1% 282,366,885 90.0% $ 2,267,014 Comml/Instit. Cooling Tower VSD--Desert Climate $ 6,408 336,718 $ 0.0431 96.2% 282,703,603 90.2% $ 2,273,422 Industrial Prem. Motor vs. Rewind $ 10,383 436,716 $ 0.0464 96.4% 283,140,319 90.6% $ 2,283,805 Residential SEHA Clothes Washer $ 66,392 3,052,546 $ 0.0476 97.4% 286,192,865 93.3% $ 2,350,197 Residential Energy Star Clothes Washer $ 57,518 2,527,540 $ 0.0498 98.3% 288,720,405 95.6% $ 2,407,715 Comml/Instit. AC, IDDEC, 150-ton Equiv. Units $ 111,958 5,072,414 $ 0.0501 100.0% 293,792,819 100.0% $ 2,519,673 7 ALL MEASURES/ALL PROGRAMS $ 2,519,673 293,792,819 $ 0.0186 8 9